Clarification on uniform guidance revision usage

Federal agencies, recipients of federal assistance, and auditors have been grappling with which version of the Office of Management and Budget (OMB) Uniform guidance two CFR 200 (2 CFR 200) should be followed on awards that don’t explicitly state the use of either pre- or post-Oct. 1, 2024, guidance.

The Council of Federal Financial Assistance (COFFA) recently provided much needed clarity on certain implementation aspects of the 2024 Revisions to two CFR 200, which are applicable to new awards issued after Oct. 1, 2024. COFFA’s memo provides further implementation guidance and flexibilities.

Gain insights into COFFA’s memo that can help your agency overcome two CFR 200 implementation challenges and maintain reporting accuracy and compliance.

2024 revisions implementation

In its memo, COFFA states that unless otherwise indicated in federal statutes, agency regulations, or federal awards, the 2024 Revisions are applicable as follows:

• New federal awards issued on or after Oct. 1, 2024. If the award is silent on which version of the two CFR 200 is applicable, recipients should apply the 2024 Revisions.
• Existing awards issued before Oct. 1, 2024. Unless an amendment to the award has been issued, recipients should continue to apply the previous version of two CFR 200.
• Amendments issued on or after Oct. 1, 2024. If the amendment doesn’t explicitly say to use the 2024 Revisions, recipients should continue to apply the previous version of two CFR 200.
• Subawards. Pass-through entities with federal awards that have been amended for the 2024 Revisions are required to amend existing subawards to apply the 2024 Revisions. If the federal award hasn’t been amended, then the previous version of two CFR 200 will continue to apply to subawards.

Most federal agencies have begun adoption of the 2024 Revisions to their agency codification which are typically located in